No link our scanner could identify as an accessibility statement.
Without a link, visitors do not find what the shop states about accessibility — see the section on the accessibility statement.
Directive (EU) 2019/882 · applicable since 28 June 2025
The European Accessibility Act for online shops
Who is in scope, which standard applies, what actually happens when an authority gets involved — and which failure types an automated check can detect. No scare tactics, sources given.
As at 26 Sep 2026 Reading time about 6 minutes Evidence base 75 shops
Are you in scope?
E-commerce is explicitly covered by Directive (EU) 2019/882; the national laws transposing it have applied since 28 June 2025.
Micro-enterprises that provide services are exempt. A micro-enterprise employs fewer than 10 people and has an annual turnover or an annual balance sheet total of no more than EUR 2 million. With 10 or more staff, or with both turnover and balance sheet total above EUR 2 million, you are not a micro-enterprise. A shop with twelve staff and EUR 900,000 turnover is covered.
Where the company is established is irrelevant. What matters is that consumers in the EU can place an order. A UK or US shop that ships into the Union is in scope.
Which standard applies
The Act itself is not technical. What binds you are the requirements in Annex I of Directive (EU) 2019/882. The technical yardstick is the European standard EN 301 549, which points to WCAG for web content — the Commission commissioned it for exactly that purpose under standardisation request M/587. For the Act it has not yet been cited in the Official Journal, so it does not yet carry the presumption of conformity under Article 15(1).
That changes nothing about the work: WCAG 2.2 Level AA is the level you bring the shop to. It changes what may be concluded from it — criteria met are a documented technical standard, not automatic proof of legal conformity. That is still measured against Annex I. Anyone telling you otherwise is selling you a certainty that does not currently exist.
In practice that means four things: the shop must be perceivable (alternative text, contrast), operable (fully keyboard-driven, visible focus), understandable (declared language, labelled forms) and robust (valid, clean markup). The Directive additionally requires the information on the accessibility of the service to be made public — see the section on the accessibility statement below.
What actually happens
Worth understanding: the Act itself sets no penalty amount. Article 30 of Directive (EU) 2019/882 only obliges member states to provide effective sanctions; each country sets the figure. There is no EU-wide range in law — anyone quoting one has estimated it from national values.
How an authority proceeds is set by national law. The authority can set a period for remediation; there is no documented typical length.
5–6 May 2026
Tribunal judiciaire de Lille (Auchan case). The court found significant accessibility failures on Auchan's site but dismissed the claim, applying an older, higher French threshold (EUR 250 million turnover, from 2005 legislation) instead of the Act's EUR 2 million threshold, which placed Auchan below it. The claimant associations announced on 6 May 2026 that they would take the case to the Cour d'appel de Douai; we have found no public record that the appeal was lodged, and no ruling.
4 June 2026
The Carrefour order. In interim proceedings, the judicial court of Caen ordered Carrefour France to make carrefour.fr and its grocery app accessible in full within six months, with a penalty of EUR 500 per day of delay. Being 71 % accessible to blind and partially sighted people was not enough: a website, the judge said, cannot be only “a little” accessible; it must be accessible in full.
2025 – 2026
Disability organisations served formal notice on several French retail chains on 7 July 2025. The organisations considered the responses inadequate and applied to the courts for urgent interim measures on 12 November 2025. Just under eleven months passed between the formal notice and the order against Carrefour.
| Jurisdiction | Range | Note |
|---|---|---|
| Germany | up to EUR 100,000 | Section 37(2) BFSG |
| Netherlands | up to EUR 900,000 or 1% of annual turnover | whichever is higher — the statutory maximum available to the ACM for e-commerce services (Art. 2.15(1) in conjunction with Art. 8.15 Wet handhaving consumentenbescherming), plus a penalty payment for continuing breaches (last onder dwangsom, Art. 2.9 Whc) |
| France | EUR 1,500 natural persons, EUR 7,500 legal persons | fifth-class offence, Art. R. 451-4 Consumer Code; for legal persons Art. 131-41 Penal Code sets five times the natural-person maximum. On a repeat offence within one year, EUR 3,000 and EUR 15,000 (Arts. 132-11 and 132-15 Penal Code) |
| Ireland | no figure stated | penalties: we do not have the statutory text in a readable form and therefore state no figure |
| Belgium | up to EUR 200,000 for bad-faith infringement | sanction levels 2 and 3 of the Code of Economic Law (Art. XV.101/1) — level 3 applies only to bad faith; Economic Inspectorate of FPS Economy, covers e-commerce and consumer banking |
| Denmark | not published | the responsible Sikkerhedsstyrelsen states the fine amount is not yet determined |
| Sweden | SEK 10,000 – 10,000,000 | sanction fee set by PTS (the regulator) |
If the authority sets a period for remediation, what counts is what you have at that point: the changed shop itself. A finding with its location in the HTML shows where that work starts.
Failure types an automated check can detect
One figure from our own automated measurement with our scanner as it stood at the time, 19 to 26 September 2026, n = 75 home pages: 61 of 75 home pages had no link our scanner could identify as an accessibility statement. The shops come from our own list of potential customers; the selection is not representative. This measurement does not show whether a shop has an accessibility statement on another page. The other cards describe failure types an automated check can detect; we do not state how often we found them.
Form fields without labels.
A placeholder does not count — it disappears as soon as someone types. In checkout it can stop the sale.
Icon buttons with no accessible name.
Basket, search, menu, account. The screen reader announces only "button". The route to checkout is not findable.
Images without alternative text.
Depending on the program, the screen reader reads out the file name, says only “image” or skips the image. If it is a product image, a blind customer cannot tell which product it is.
No skip link.
Keyboard users must tab through the entire navigation again on every page.
Insufficient contrast.
4.5:1 is required for normal text. Check light-grey helper text on white first.
Focus indicator removed.
outline:none with no replacement. Keyboard users can no longer see where they are.
The accessibility statement
Service providers in scope must make publicly available how their service meets the accessibility requirements (Directive (EU) 2019/882, Article 13(2) and Annex V); micro-enterprises providing services are exempt (Article 4(5)). That is what the accessibility statement is for. Our template covers six things:
- Compliance status — partially or non-compliant; full compliance only after an assessment of every success criterion
- The standard applied — EN 301 549 / WCAG 2.2 AA
- Known limitations, named and explained
- A contact route for feedback
- Dates of preparation and last review
- The enforcement procedure in your member state
Two mistakes to avoid. First, claiming "fully compliant" while measurable failures exist — that turns a defect into a false declaration. Second, entering a remediation date nobody has committed to. Write "open" rather than a date that will pass.
Our own statement is public, including the points still open on our side.
Find out where you stand
We test your home page at no charge with 24 automated checks and reply with the three most severe findings in plain language, each with its location in the HTML and WCAG criterion. No call, no deck. If there is nothing serious, we say so.
Scope of testing
Five49 runs 24 automated, rule-based checks. They look for failures in 15 of the 55 WCAG 2.2 Level A and AA success criteria. Automated checks can find failures but cannot show that a criterion is met. All 55 criteria, including these 15, therefore also need manual review with a screen reader, keyboard and magnification. The result is neither a conformance statement nor legal advice and gives no assurance of any legal outcome. For an assessment of your own situation, consult a qualified lawyer.